Archive for the International Taxation & Reporting Category

IRS CI Division Chief Unveils International Tax Enforcement Group

enter The IRS Criminal Investigation Division (IRS-CI) is putting together a new international tax enforcement group, according to IRS-CI Chief Don Fort. This information was revealed publicly to reporters for the first time during an August 2 conference call. The new initiative is expected to be fully operational…

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IRS Highlights Form 1042-S Filing, Common Errors, Amended Forms and Extensions

can i go to jail for defaulting on a payday loan The IRS has reminded withholding agents of their responsibilities, some reporting changes and some common errors. The IRS also described filing requirements for non-U.S. citizens in certain circumstances. The due date for Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, is March 15. To request…

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Bill Introduced to Increase Foreign Investment in U.S. Real Estate

source site On Thursday, April 30th, two senior members of the House Ways and Means Committee, Kevin Brady, R-Tex., and Joe Crowley, D-N.Y., reintroduced legislation, the Real Estate Investment and Jobs Bill of 2015 (HR 2128), that would remove a 1980s era tax provision that discourages foreign investment in U.S.…

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Securities Industry and Financial Markets Association (SIFMA) Criticizes FATCA

stock secured loan The entire burden for implementing the Foreign Account Tax Compliance Act (FATCA) falls on U.S. and foreign financial services firms, according to the Securities Industry and Financial Markets Association (SIFMA). In addition, a former acting IRS commissioner who helped oversee the rollout of the anti-tax evasion law…

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Six Key Business Tax Issues To Watch For in 2015

click here As companies assess the political landscape for 2015 they will also find an evolving economic outlook, and a heightened focus on tax transparency that could add “incredible uncertainty” to the tax outlook in 2015, says KPMG. Therefore, business executives will need to keep a close eye on…

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Interest Paid by Foreign Disregarded Entity Was U.S. Source Income

click here The IRS Chief Counsel determined that interest paid by a foreign disregarded entity of a U.S. domestic corporation to a foreign corporation was U.S. source income under Code Sec. 861(a)(1) and, therefore, subject to withholding under Code Sec. 1442. The foreign corporation payee was a controlled foreign…

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Action Needed to Ensure Tax Compliace with FIRPTA

no income verification payday loans According to new audit report from the Treasury Inspector General for Tax Administration (TIGTA), current IRS procedures are insufficient to ensure that all foreign seller real estate transactions subject to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) are in fact compliant with FIRPTA.…

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US Treasury Official Discusses BEPS and Other International Tax Developments

Robert Stack, Treasury deputy assistant secretary (International Tax Affairs), predicts that the department will face a difficult year in 2015 as it begins to tackle several of the tougher issues listed in the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action…

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Anti-Inversion Proposals Put 42,000 U.S. Jobs at Risk of Going Overseas

Congressional and administrative proposals are failing to address the underlying incentives driving inversions and therefore, putting 42,000 U.S. jobs at risk of going overseas, according to new research from the American Action Forum (AAF), a center-right think tank. The AAF study, released on September 4, also found…

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IRS and Treasury Take Action Against Corporate Inversions

The Treasury and the IRS have announced that they will be taking targeted action against corporations employing a technique known as a tax inversion in order to avoid taxation, and have issued a fact sheet and a Notice in that respect. What happens with an inversion, is…

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